Since they were first initiated in March 2014 in response to a number of actions by Russia in relation to the unstable situation in Ukraine, Canada’s trade, financing and transaction sanctions against the Putin regime have grown increasingly complex and more broadly encompassing.
Clifford Sosnow, an international trade lawyer with Fasken Martineau DuMoulin LLP, recently published an article which clearly outlines the expanded scope and legal reach of the trade sanctions currently in place and should be required reading for anyone concerned about not falling afoul of the various prohibitions encompassed by the government’s Special Economic Measures (Russia) Regulations.
Importantly, Sosnow notes that while the Canadian government’s actions have been coordinated with its counterparts in the U.S. and the EU, the regulations are not an exact match to those passed elsewhere. Owing to important differences in scope and coverage, Sosnow cautions Canadian companies “to avoid assuming that compliance with Canada’s Russia Regulations can be obtained by complying with the U.S. or EU sanctions.”
Sosnow also warns companies that the utmost diligence is required when it comes to compliance with the regulations considering “recent prosecution activity by the RCMP indicates that the Canadian government is prepared to aggressively investigate and prosecute those acting in alleged violation of Canadian sanctions law and will continue to do so.”
Click here to read the article.